Supporting Statement

for

Information Collection Request

Information Requirements for Importation of Nonconforming Vehicles (Renewal)

EPA ICR 0010.12

April 2010

Compliance and Innovative Strategies Division 

Office of Transportation and Air Quality 

Office of Air and Radiation 

U.S. Environmental Protection Agency
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PART A OF THE SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

1. IDENTIFICATION OF THE INFORMATION COLLECTION

 (a) TITLE OF THE INFORMATION COLLECTION

Information Requirements for Importation of Nonconforming Vehicles (40CFR Part 85, 

Subparts P and R) (Renewal), EPA ICR Number 0010.12, OMB Control Number 2060-

0095

 (b) SHORT CHARACTERIZATION (ABSTRACT)

 The Clean Air Act requires motor vehicles and engines imported into the U.S. to 

conform to applicable emission requirements. This Information Collection Request 

(ICR) covers importation reporting requirements for light-duty vehicle, light-duty truck, 

and on-road motorcycle vehicles and engines. The information collection instruments are 

Form 3520-1 ("Form 1") for initial entry, and Form 3520-8 ("Form 8") for final entry (see 

below). All heavy-duty on-road and all non-road vehicle and engine importation 

reporting requirements are now covered by ICR 1723 (OMB 2060-0294). The two 

programs use separate forms, have differing regulatory provisions, and are processed by

differing staffs. Most importers are also required to apply for and obtain a certificate of 

conformity from EPA; that information burden for the light-duty and motorcycle 

certification program is covered by ICR 0783 (OMB 2060-0104). There is some program 

overlap between the present ICR and 0783 because testing for Independent Commercial 

Importers (ICIs) is reported both on Form 8, covered by this ICR, and, initially and in 

more detail, for certification purposes, via ICR 0783. (Similarly, all importing light-duty

vehicle and motorcycle manufacturers, and not just ICIs, use Form 1.) Thus, the 

certification information burden is covered in ICR 0783 and the (different and less 

detailed) testing burden for imports subsequent to certification for ICIs in this ICR. 

 The burden of submitting the fee and associated forms is covered by ICR 2080 (OMB 

2060-0545).

 The post-certification, final-entry testing burden for light-duty vehicle imports falls 

into two categories. For the category of certified light-duty ICIs, a city test (the “FTP”) is 

required for every third vehicle imported under a certificate for the first 300 vehicles 

imported, and every fifth thereafter (40 CFR 85.1505). The second light-duty imports 

category is “mod and test”, which applies to vehicles whose original production year is

six or more prior to the year of importation. Each such vehicle must be modified to meet 

applicable emissions requirements and tested with the FTP (40 CFR 85.1509). In the first

category, each FTP test will be accompanied by a two-hour evaporative emissions test, 

and in both categories, by a highway test in order to compute a combined fuel economy 

number to comply with fuel economy requirements. Form 8 includes spaces for reporting 

the test results and combined fuel economy for those vehicles that undergo them. A very
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limited number of nonconforming motorcycles have been imported in the last three years. 

Most are imported under a provision (40 CFR 85.1505(a)(2)(i)) that allows for no 

additional testing beyond the original certification testing. Otherwise, testing 

requirements are the same as those for light duty vehicles except that a highway test is 

not required. 

 Most ICIs contract with a broker to do some of the imports process and a testing 

laboratory to perform the necessary tests. The testing lab also performs whatever 

modifications are necessary to bring the vehicle up to certification standards. 

 The Compliance and Innovative Strategies Division (CISD) in EPA’s Office of 

Transportation and Air Quality collects information and requires some recordkeeping to 

help insure that imported vehicles and engines are brought into compliance with federal

emission requirements or that they qualify for exemption or exclusion from them. 

“Nonconforming” refers to the vehicles and engines that are not constructed to EPA 

certification standards and therefore must meet various additional requirements, such as 

testing, prior to being certified and available for sale in the U.S. The information is also 

used by the U.S. Customs Service (Customs), state regulatory agencies, businesses, and 

individuals to verify whether or not vehicles are in compliance.

 Information collected includes vehicle identification data, U.S. Customs entry

statements that such information is correct, and summary emission test results. The 

information is either stored in a computer database, or retained in document form. The 

information is used to monitor compliance of imports and respond to inquiries from the 

public concerning the compliance status of specific imported vehicles. This information 

is collected on two forms (attached in ICRAS):

EPA Form 3520-1. This form is used by importers who are applying for entry

into the U.S. of light-duty vehicle, light-duty truck, and motorcycle vehicles or engines, 

whether conforming, nonconforming, exempt, or excluded. The form identifies to all 

parties involved the category of import and the requirements that are appropriate to that 

category. The form goes from the importer or its agent (broker) to Customs, which 

stamps the form and forwards it in batch to EPA. EPA gathers the forms in Ann Arbor 

where they are logged and filed for future reference. The form is posted on EPA’s 

imports website, http://www.epa.gov/otaq/imports/index.htm .

EPA Form 3520-8. This form is used by ICIs to request “final admission” of a 

nonconforming vehicle or engine upon their certification that it has been brought into 

compliance with Federal emission requirements. The form is held for fifteen days, during 

which the ICI can not release the vehicle for sale or to its owner. This gives EPA a 

chance to conduct any review or oversight, including confirmatory testing, deemed 

necessary before the vehicle or engine is released. 

The EPA requests a waiver from posting the expiration date of the OMB clearance on 

these forms. Because Form 1 is used by both Customs, EPA, and importers, repeated 

uploadings to the imports website and revisions to reflect expiration of the clearance 
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deadline, continuation of clearance pending review, and the new expiration date may be 

burdensome, with the existence of revisions inadequately communicated to users. Form 8 

has a limited number of users who in the past have had to be individually contracted to 

inform them of substantive updates. Posting of Form 8 on the imports website is currently 

under consideration. Both forms have been in use for many years and importers are 

familiar with their features. 

 The information collection will involve an estimated yearly 12,352 responses from

12,005 respondents at an Operations & Maintenance (O&M) cost of $90,894, a capital 

cost of $73,353, and a labor cost of $370,803 (see Table 1 below).

2. NEED FOR AND USE OF THE COLLECTION

(a) NEED/AUTHORITY FOR THE COLLECTION

 Joint EPA and Customs regulations at 40 CFR 85.1501 et seq., 19 CFR 12.73, and 19 

CFR 12.74, promulgated under the authority under the Clean Air Act (Sections 203 and 

208), give authority for the collection of the information. The collection helps insure 

compliance of imported vehicles and engines with federal emissions requirements, which 

helps meet the Agency goal of reducing air pollution. Without this information, EPA and 

Customs officials could not confirm that imported vehicles and engines conform to U.S.

emission requirements, and consequently would not be able to allow importation or sale 

of these vehicles and engines.

 (b) PRACTICAL UTILITY/USERS OF THE DATA

 The information on Form 1 and Form 8 is used by Customs and/or Agency personnel 

to verify that all Federal emission requirements (or exemptions or exclusions thereto) 

concerning imported nonconforming light-duty motor vehicles and motorcycles are met. 

The information is also used to identify and prosecute violators of the regulations and to 

monitor the program in achieving the objectives of the regulations. It is also used to 

answer public inquiries concerning the compliance or exempted or excluded status of 

particular motor vehicles. Public access to this information is not direct but rather through 

the EPA’s imports section and the Automotive Imports Helpline in order to maintain 

security of information protected under the Privacy Act. 

3. NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION 

CRITERIA

 (a) NON-DUPLICATION

 A search of the Government Information Locator System (GILS) found no other 

program or agency collecting this information. As explained above, Form 1 is necessary

to identify, at the point of importation, the applicable category of the vehicle or engine 

for regulatory purposes; Form 8 is necessary to report test results to EPA (where 

required) and alert it of pending release to the owner. As stated on Form 1, vehicles that 
5

are primarily manufactured for use on public roads are also required to file an HS-7 

Declaration Form to identify the basis for the vehicle’s admission under the laws 

administered by the Department of Transportation (DoT). EPA had discussions with the 

DoT in late 2005 that considered whether a combined form would be feasible, and the 

conclusion was that a single form was not practical at this time because of the unique 

requirements of each program and the different agencies administering them. 

 (b) PUBLIC NOTICE

 A Federal Register notice was published, soliciting public comment for this ICR on 

January 22, 2010 (75 FR 3723). A copy of the draft Supporting Statement was also 

placed in the docket. No comments were received. 

 (c) CONSULTATIONS

 Consultations have been made with ICIs to discuss form revisions, to update burden 

and cost estimates, and to receive suggestions about the operation of the program. The 

following ICIs were contacted:

Auto Enterprises, Inc.

850 N. Rochester Rd.

Clawson, MI 48017

Rep: Mr. Philip Trupiano

Phone: (248) 723-6677

J.K. Technologies , L.L.C. 

3500 Sweet Air Street

Baltimore, MD 21211

Rep: Mr. Jonathan Weisheit

Phone: (410) 366-6332

Compliance and Research Services, Inc. 

1701 Front Street

Plainfield, NJ 07063-1066

Rep: Bob DePalma

Phone: (908) 561-1824

 (d) EFFECTS OF LESS FREQUENT COLLECTION

 Since reporting is done only at the time of initial and “final” entry, the effects of less 

frequent collection would be to seriously undermine the Agency's ability to determine 

whether vehicles being imported meet applicable emission requirements. Consequently, 

the Agency would not be able to allow entry of vehicles being imported. Therefore, less 

frequent collection is not feasible.
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 (e) GENERAL GUIDELINES

 This ICR requires that ICIs notify EPA when requesting final admission for vehicles 

(Form 8) and this may occasionally result in reporting more often than quarterly if 

vehicles are tested and ready for sale more frequently than quarterly. This requirement is 

necessary for EPA to have the opportunity to inspect vehicles prior to release from the 

ICI. If EPA only required quarterly reports, either the ICI would have to hold vehicles 

and release them on a quarterly basis or EPA would not likely have the opportunity to 

inspect or require confirmatory testing of vehicles imported by the ICI.

 EPA's regulations require that ICIs retain records for a period of six years from the 

date of entry (40 CFR 85.1507(a)). ICIs are responsible for the same emissions 

warranties that apply to original manufacturers, generally extending to 8 years or 80,000 

miles for major emission control components. The Clean Air Act requires that light-duty 

vehicles meet federal emission standards throughout their useful lives, which is defined 

by the Clean Air Act to be either 10 years or 100,000 miles (Sec. 202(d)); these 

requirements are implemented through the certification process for ICIs just as they are 

for original manufacturers. The imports regulations specify that the useful life period 

starts from the date that the vehicle is released to the owner by the ICI. The six-year 

record retention requirement is the minimum considered consistent with these 

obligations.

 

 (f) CONFIDENTIALITY

 Any information submitted to the Agency for which a claim of confidentiality is 

made will be safeguarded according to policies set forth in Title 40, Chapter 1, Part 2, 

Subpart B - Confidentiality of Business Information (CBI) (see CFR 2). The public is not 

permitted access to information containing personal or organizational identifiers. This 

collection complies with the Privacy Act of 1974 and OMB Circular A-130.

 (g) SENSITIVE QUESTIONS

 There are no sensitive questions.

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

 (a) RESPONDENTS/NAICS CODES

 The Light-duty Vehicle Group and Imports Team of CISD collect information from 

individual importers and both small and large companies that import light-duty vehicle, 

light-duty truck, and on-road motorcycle vehicles or engines. The NAICS code for 

respondents is: 1) 423110, Automobile and Other Motor Vehicle Merchant Wholesalers;

and 2) 441200, Other Motor Vehicle Dealers. 
7

 (b) INFORMATION REQUESTED

 (i) Data Items

 The data requested in reports include:

 - vehicle identification number

 - vehicle make

 - vehicle model

 - model year of the vehicle

 - port of entry

 - date of entry

 - entry number

 - importer name, address and telephone number

 - owner name, address, telephone number and SSN or EIN

 - emission test results

 - applicable EPA certificate of conformity

 - fuel economy

 - test date

 - modification date

 - name of emissions test laboratory

 - vehicle storage location

 - justification for an exclusion or exemption, if applicable and records are maintained 

on:

 - documents related to certification, modification, importation, storage, registration or 

emission testing

 - bills of sale, invoices, or purchase agreements

 - documents providing parts identification data associated with the emission control 

system

 - documents providing evidence of the initiation of the "hold period"

 (ii) Respondent Activities

 To complete the collection, the respondent would:

 -read form instructions

 -collect data and complete forms

 -conduct required emission testing (ICIs only)

INFORMATION REQUIREMENTS FOR 

IMPORTATION OF NONCONFORMING MOTOR VEHICLES 

AND MOTOR VEHICLE ENGINES

(40 CFR PART 85, SUBPARTS P and R) (Renewal)

INFORMATION REQUIREMENTS CITATION
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I. ICI requirements

- Reporting

- Application for final admission 85.1505(a)

 (certified)

- Reasonable assistance during inspection, 

85.1506(c),(g)(4)

 including copies of records or documents 85.1506(b)(2)

- Application for final admission 85.1509(b)

 (modification/test)

- Repair and retest 85.1509(g)

- Maintenance instructions, attestation, 85.1510(a)

 parts list

- Altitude compensator instructions, attestation 85.1510(b)

- Emission warranties, attestation 85.1510(c)

- Emission labeling, attestation 85.1510(d)

- Fuel economy labeling, attestation 85.1510(e)

- Gas guzzler tax forms, attestation 85.1510(f)

- Reply to notice of suspension or 85.1513(f)(3)(ii),

 revocation 85.1513(f)(3)(iv)

 85.1513(f)(6)

- Request for hearing 85.1513(f)(3)(iii)

Recordkeeping

- Certification, modification, test, purchase, 85.1507

 sale, storage, registration, importation 

- Owners or ultimate purchasers 85.1508(b)

- Maintenance instructions, parts list, 85.1510

 altitude compensator instructions, 

 emission warranties, emission labeling,

 fuel economy labeling

II. Requirements applying to all importers

- Notification of conditional admission 85.1504(a)

- Request for prior approval (exemption), 85.1511(b),(g)

 request for extension of exemption 

- Request for prior approval (exclusion) 85.1511(c)-(g) 

- Attestations, copy of paid invoice 85.1512(f)

- Claim of confidentiality 85.1514

5. THE INFORMATION COLLECTED: AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY, AND INFORMATION MANAGEMENT

 (a) AGENCY ACTIVITIES
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 Form 1s are collected as they are received from Customs and, in some cases, from 

importers or their agents and collected by the Imports Team; Form 8s are collected by the 

Imports Team and copies distributed to certification staff; since late 2005 the data from 

Form 8 has been entered into the Automated Imports Tracking System (AITS). After 

receiving the information, EPA uses it to determine whether vehicles meet EPA 

requirements and whether to conduct investigations or require confirmatory testing, and 

retains it in order to respond to public, State government, and Federal government 

inquires. In addition, ICI applications for certification are now included in the “Verify”

information system, effective with the 2010 year imports. 

 (b) COLLECTION METHODOLOGY AND MANAGEMENT

 Form 1 is available in fillable .pdf form downloadable from EPA's imports website. 

Form 8 has recently been converted to fillable and posting at the same site is under 

consideration. Forms are submitted to EPA by the importer or its agent or Customs after 

being filled out at the port of entry in the case of Form 1 and by the importer or its agent 

in the case of Form 8. Both Customs and CISD use the information to determine if 

vehicles meet EPA requirements. CISD retains information in the AITS and document 

form in order to respond to public, State government, and Federal government inquires, 

which are handled by CISD staff.

 (c) SMALL ENTITY FLEXIBILITY

 Small entities that are required to submit information to EPA have been doing so by

completing and submitting EPA paper forms. EPA regulations provide, as an alternative, 

for submission of imports data electronically (e.g. 40 CFR 85.1505(a), 85.1509(b) & (c)). 

Under EPA guidance (CCD-02-04; (http://www.epa.gov/otaq/cert/dearmfr/ 

dearmfr.htm), ICIs qualify per se as small volume manufacturers entitled to the special 

provisions available to all certifying small manufacturers under EPA’s certification 

regulations. As stated above, ICI certification activities are now conducted electronically

via “Verify”. Form 8s are currently submitted electronically as email attachments or in 

paper form. 

 (d) COLLECTION SCHEDULE

 The information is not subject to a collection schedule, but is collected at the time of 

vehicle entry and when the vehicle is ready for final admission by EPA.

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

 (a) ESTIMATING RESPONDENT BURDEN (HOURS)

 See the table below. Each form is estimated to take 0.5 hours to complete. 

Completing required post-certification testing is estimated at 28 hours per test. There is 

no requirement for importers to keep copies of Form 1. Extra recordkeeping for Form 8s 
10

were formerly estimated at an additional 0.5 hour per form; however, these recordkeeping 

burdens are more appropriately attributed to the certification ICR, which will be adjusted 

accordingly during the next renewal. There is no recordkeeping burden associated with 

Form 8 other than adding it to the existing records for the certified family. 

 (b) ESTIMATING RESPONDENT COSTS

(i) Labor Costs

 Labor costs are considered to be more closely approximated by the motor vehicle 

manufacturing industry, NAICS 336100, than retail and wholesale trades in vehicles that 

do not involve testing and modification. Rates for engineering managers, mechanical 

engineers, and secretaries (except legal, medical, and executive) are from the May 2008 

National Industry-Specific Occupational Employment and Wage Estimates 

(http://www.bls.gov/oes/2008/may/naics4_336100.htm, accessed December 10, 2009). 

With a 160% overhead multiplier, these are $87.30, $60.40, and $30.50, respectively.

Test labor costs are $55.82 per hour based on ICR 0783.54. 

(ii) Operations and Maintenance (O&M) Costs 

 Operations and maintenance costs apply only to Form 8 and were calculated based on 

responses received from the ICIs contacted. The Operations and Maintenance cost for 

reporting ordinarily involves a purchase of services from a broker who complete a 

package of importation forms (including those of other agencies) and files them with both

Customs and EPA. This cost is estimated as a component of overall broker activities to 

import a vehicle or engine, and incorporates a $2 per form paperwork cost for broker 

form handling within overall broker activities, and a $3 per form mailing cost for Form 

8s. O&M costs associated with testing are much less than those for certification vehicles; 

post-certification vehicles do not have mileage accumulation or durability demonstration 

requirements or consequent vehicle depreciation; vehicle preparation is minimal. O&M 

testing costs are estimated at $651 per vehicle. Costs associated with modification of 

vehicles necessary to bring them up to certification standards are excluded: they are not 

reported on the imports forms, they vary widely depending on the vehicle being 

imported, and they therefore can not be predicted or accounted from one year to another; 

finally, they are analogous to, for example, the costs of catalytic converters and other 

emissions control technologies that original manufacturers are required to install in 

vehicles in order to comply with the Clean Air Act, and which are not included in the 

certification paperwork burden. 

 

 (iii) Capital/Startup vs. Operations and Maintenance (O&M) Costs 

 
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Capital/Startup vs. Operation and Maintenance (O&M) Costs

O&M Capital/Startup (unamortized)

Capital/Startup 

(amortized) Total Dep. Cap + O&M

Filing

Form 3520-1 $0 0 $0 $0 

Form 3520-8 $1,056 0 $0 $0 

Testing 

Form 3520-8

 Regular ICI $62,496 $358,400 $51,028 $113,524 

 Mod and Test $27,342 $156,800 $22,325 $49,667 

Total $90,894 $515,200 $73,353 $164,247 

 (iv) Capital/Start-up Costs

 Consistent with ICR 0783, a capital cost of $4,000,000 for a test facility capable of 

conducting 750 combined FTP and highway tests per year has been allocated on a pertest basis. Following ICR 2387.01, which is the Light Duty Greenhouse Gases rule ICR, 

this is allocated 0.7 to the FTP portion. For ICIs, these test facility costs will in most 

cases be covered by contractual costs between the importer and a testing laboratory. 

As mentioned above, these costs listed here are not initial certification costs but the postcertification test costs for additional imported vehicles. As with other ICRs, these capital 

costs are annualized and subject to 7% interest depreciation but are considered to be ongoing rather than startup capital costs in the sense that as facilities are depreciated they

are continually being replaced. 

 (c) ESTIMATING AGENCY BURDEN AND COST

 The imports program is administered by EPA's Compliance and Innovative Strategies 

Division (CISD). Forty percent of one Full Time Equivalent employees (FTE), GS 12/3; 

twenty percent of one Senior Environmental Employment (SEE) Program employee (the 

SEE Program is an employment program for older workers authorized by the 

Environmental Programs assistance Act, passed by Congress in l984, and provides 

employment opportunities to senior citizens age 55 and over); and a portion of the work 

assignment under a government contract are allocated to imports activities. Government 

cost is based on a GS-12, step 3 salary for professional engineers ($63,341 per year) 

obtained from the Office of Personal Management 2009 Salary Table; and $15.53 per 

hour for SEE employees, with a 1.6 multiplier for overhead applied to both, yielding 

$40,538 and Based on the 2006 GS pay schedule, EPA estimates an hourly $34.35 for 

the FTE, then multiplies the hourly rates by the standard government benefits 

multiplication factor of 1.6, at a cost of $45,728, and a cost of $9,939 for the SEE;

$106,000 is estimated for the contractor. The contractor estimate is based upon the work 

assignment rather than an estimate of hours. An estimated total agency cost of $161,667
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per year is therefore allocated to imports activities. These activities include both on-road

imports (this ICR) and nonroad imports (ICR 1723; OMB 2060-0320). An estimated 90% 

of these activities currently involve on-road imports; consequently, $145,500 is the 

estimate for the agency cost for purposes of this ICR. 

 (d) Estimating the Respondent Universe and Total Burden and Costs

In the previous renewal we estimated that 12,000 Form 1s are submitted annually, 

averaging one respondent per form, and 352 Form 8s from five ICIs, based on a hand 

count of Form 8s received in 2005 and 2006, plus an estimate based on actual and 

projected imports from one high-volume importer covering four original production 

years. The total number of responses was therefore estimated as 12,352. The estimated 

number of respondents was 12,005. 

Both estimates are approximate and variable. For Form 1, our information is that 

Customs does not require every importer subject to the regulations at 19 CFR 12.73 to fill 

out the form; furthermore, the forms that are forwarded to us by Customs or by importers 

may not represent every form that is filled out. For Form 8, the number of ICIs is small, 

the number of engine families certified is small, and the number of vehicle imports within 

an engine family can vary widely. All these factors add up to produce significant "small 

number fluctuations". In 2005 there were 21 ICI families, including one high-volume 

importer that greatly multiplied the number of FTP tests employed. In 2008 there were 10 

families, and without the high-volume importer. Consequently, to insure that EPA has the 

authority to accommodate the possible level of forms and tests needed under the 

collection authorization, we have retained the numbers of forms and tests from the 

previous renewal.

For each engine family, one imported vehicle is used for certification testing; 

therefore, while the forms count does not decrease, the testing responses is decreased by 

the number of import engine families. For model year 2005, 21 ICI engine families were 

certified; the count of 300 regular ICIs was reduced by 11 to total 289 vehicles subject to 

post-certification testing; every third vehicle results in an estimate of 96 tests; the total of 

52 mod & test vehicles was reduced by 10 certification vehicles; the remaining 42 are 

subject to tests. 

 (e) Bottom Line Burden Hours and Cost

 (i) Respondent Tally

Respondents 12,005

Responses 12,352

Burden Hours 9,350

Labor Cost $370,803

Operating Cost $90,894

Capital Cost $515,200

Capital Cost (Annualized, discounted) $73,353
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Total (Annualized) $535,050

 (ii) Agency Tally

Employees 2

Employee Labor Cost $50,100

Contract Labor Cost $95,400

Total Cost $145,500

 (f) Reasons For Change In Burden

 This ICR follows the burden hours assumptions of the previous renewal for filling out 

the forms themselves, as well as the testing cost elements. The previous Supporting 

Statement and Federal Register notices reported depreciated capital costs consistent with 

the treatment in all other ICRs dealing with similar testing costs, but the authorized 

burden requested was mistakenly based on un-depreciated capital costs; correcting this 

results in a large reduction in the request without a change in the underlying program. 

Other changes in burden reflect minor improvements to the hour and cost estimates for

these elements to reflect information obtained for similar elements in intervening ICRs. 

This has resulted in an increase in O&M costs, a decrease in capital costs, and a decrease 

in hours associated with FTP tests. The agency and importer labor costs have been 

updated with more recent cost figures for government and industry. The agency contract 

cost for the imports program is down over $50,000 from the previous report. 

 (g) BURDEN STATEMENT

 Public reporting burden for this collection is estimated to average 45.4 minutes per 

response. Burden means the total time, effort, or financial resources expended by persons 

to generate, maintain, retain, or disclose or provide information to or for a Federal

agency. This includes the time needed to review instructions; develop, acquire, install, 

and utilize technology and systems for the purposes of collecting, validating, and 

verifying information, processing and maintaining information, and disclosing and 

providing information; adjust the existing ways to comply with any previously applicable 

instructions and requirements; train personnel to be able to respond to a collection of 

information; search data sources; complete and review the collection of information; and 

transmit or otherwise disclose the information. An agency may not conduct or sponsor, 

and a person is not required to respond to, a collection of information unless it displays a 

currently valid OMB control number. The OMB control numbers for EPA's regulations 

are listed in 40 CFR part 9 and 48 CFR Chapter 15.

To comment on the Agency's need for this information, the accuracy of the 

provided burden estimates, and any suggested methods for minimizing respondent 

burden, including the use of automated collection techniques, EPA has established a 

public docket for this ICR under Docket ID Number EPA-HQ-OAR-2009-0982. 

Submit any comments related to the ICR for this rule to EPA and OMB. Submit your 

comments, identified by Docket ID No. EPA-HQ-OAR-2009-0982, by one of the 
14

following methods: 

www.regulations.gov: Follow the on-line instructions for submitting comments.

Fax: (202) 566-1741. 

 Mail: Environmental Protection Agency, EPA Docket Center (EPA/DC), 

Air and Radiation Docket, Mail Code 6102T, 1200 Pennsylvania Avenue, N.W., 

Washington, DC 20460, Attention Docket ID No. EPA-HQ-OAR-2009-0982. In 

addition, please mail a copy of your comments on the information collection 

provisions to the Office of Information and Regulatory Affairs, Office of 

Management and Budget (OMB), Attn: Desk Officer for EPA, 725 7th St. NW., 

Washington, DC 20503. 

Hand Delivery: Docket Center, (EPA/DC) EPA West, Room 3334, 1301 

Constitution Ave., NW, Washington, DC., Attention Docket ID No. EPA-HQ-OAR2009-0982. Such deliveries are only accepted during the Docket’s normal hours of 

operation, and special arrangements should be made for deliveries of boxed 

information 

Docket ID Number EPA-HQ-OAR-2009-0982, is available for public viewing at the Air 

and Radiation Docket in the EPA Docket center (EPA/DC), EPA West, Room B102, 

1301 Constitution Avenue, NW, Washington, D.C. The EPA Docket Center Public 

Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding 

legal holidays. The telephone number for the Reading Room is (202) 566-1744, and the 

telephone number for the Air and Radiation Docket and Information Center is also (202) 

566-1744. An electronic version of the public docket is available at 

www.regulations.gov. 

.
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Table 1: Annual Respondent Burden and Cost --Information Requirements for 

Importation of Nonconforming Vehicles (40CFR Part 85, Subparts P and R) 

(Renewal) 

Burden Item

Number 

Activities

Hours per 

Activity Total Hours Labor 

Filing

Form 3520-1 12,000 0.5 6,000 $183,000 

Form 3520-8 352 0.5 176 $10,630 

Testing

Form 3520-8

 Regular ICI 96 23 2,208 $123,251 

 Mod and Test 42 23 966 $53,922 

Total 12,352 0.5 9350 $370,803